https://www.taxtmi.com/highlights?id=94160 ITAT allowed the appeal and set aside penalty under s.271(1)(c), holding that disclosure of additional income during survey, subsequently reflected in the return filed under s.139(1) and in the return under s.153A and accepted by the AO, does not constitute concealment as a matter of law. The Tribunal applied the strict construction applicable to penal provisions and held the decisive test is whether the return contains complete particulars of income. Absent omission in the return and independent corroborative evidence of concealment, addition or penalty based solely on a survey disclosure (a loose paper) is unsustainable. The penalty was therefore quashed. en-us Fri, 14 Nov 2025 09:42:55 +0530 Fri, 14 Nov 2025 09:42:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94160 ITAT allowed the appeal and set aside penalty under s.271(1)(c), holding that disclosure of additional income during survey, subsequently reflected in the return filed under s.139(1) and in the return under s.153A and accepted by the AO, does not constitute concealment as a matter of law. The Tribunal applied the strict construction applicable to penal provisions and held the decisive test is whether the return contains complete particulars of income. Absent omission in the return and independent corroborative evidence of concealment, addition or penalty based solely on a survey disclosure (a loose paper) is unsustainable. The penalty was therefore quashed. Highlights Income Tax Fri, 14 Nov 2025 09:42:55 +0530 https://www.taxtmi.com/highlights?id=94160